US v. Mangarella: In 2008 Mangarella was convicted of conspiracy and fraud and sentenced to 600 months in prison, which was eventually reduced to 360 months (the 600-month sentence was determined to be a de facto life sentence, in violation of diplomatic assurances made to Costa Rica when it extradited Mangarella and his coconspirator). In 2019, Mangarella filed a motion for compassionate release based on his advancing age and medical conditions, which was denied. In 2020, Mangarella moved for the district court to reconsider its denial in light of the emerging COVID epidemic, which the district court also denied. Later that year, Mangarella filed another motion for reconsideration based on a large COVID outbreak at the facility where he was incarcerated. With regard to the relevant 3553(a) factors, he argued that while the severity of his offense called for a severe sentence, it did not call for one that included “exposure to a life-threatening illness.” The Government initially supported Mangarella’s motion, but after pushback from the judge, changed course. The district court again denied the motion, resting its decision on an analysis of the 3553(a) factors, but notably not addressing Mangarella’s COVID-based argument.
On appeal, the Fourth Circuit reversed the district court’s denial of Mangarella’s motion for compassionate release. The court recognized that the district court’s 3553(a) analysis was “relatively thorough” and that its failure to directly address the COVID-related argument “does not by itself” show the district court did not consider it. However, in its berating of the Government’s initial position in support of the motion the district court “appeared to take the view that it was in appropriate to consider COVID-19 or Mangarella’s particular susceptibility” in both the eligibility and 3553(a) portions of the case. Therefore, remand was required.
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